Response to RCGP revised guidance on Good Medical Practice

Introduction

MPS has long been supportive of the introduction of revalidation; however, we fully recognise the practical difficulties of introducing the scheme. We commend the RCGP for their swift action in this area and for their future work in piloting the scheme.

General comments

Overall the guidance is clear and comprehensive, and the examples given of exemplary and unacceptable practice are helpful. However, the lack of examples of acceptable practice may cause confusion.

The document refers to either ”medical defence organisations” or ”medical defence society”. We would suggest that the appropriate collective phrase is either “medical defence organisations” (MDOs) or “medical protection organisations” (MPOs).

Specific comments

Page 16, sixth bullet point under “the unacceptable GP” – The second part of the sentence has been reworded from the previous version.  We suggest retaining the previous wording as it was more clearly expressed.

Pages 17 and 19 – A section entitled “Decisions about access to medical care” appears on each of these pages, but deals with different subjects.  The sections do not appear to be linked and do not follow on from each other, so it is likely to cause some confusion. 

Page 26, paragraph three  – The third  sentence is unclear and should read either “in supporting” or “to support”.

Page 27, third bullet point – It is unclear from the preceding text what is meant by “offering personal support”.  Supporting the appraisee in improving and maintaining patient care, as recommended in the preceding paragraph, is different to providing personal support, which could be interpreted in a variety of ways. This point should be altered to be consistent with the text.

Page 32, end of second paragraph – The last sentence of this paragraph is incorrect as it does not correctly reflect the situation.  There are a variety of different situations in which a GP may need to share adult patient information without the patient’s consent.  For example, for an adult lacking capacity, the GP should disclose information if it is in the patient’s best interests to do so, to whomever is the relevant person.  Disclosures may be justified in the public interest without the consent of a competent patient. There are also situations in which disclosures of information may be required under statute, such as under public health legislation.

Should you require further information about any aspects of this consultation, please do not hesitate to contact me.